Organisational Model and Code of Ethics

To ensure that the Company’s business activity is always conducted in conditions of fairness and transparency, Focus Investments has adopted an “Organisational Model” in line with the requirements of Italian Legislative Decree No. 231 of 8 June 2001 (the “Decree”). The Organisational Model was approved by the Board of Directors on 17 October 2016, updated on 25 January 2022 and approved again by the Board of Directors on 21 March 2022.

The Company believes that the adoption of the Organisational Model and the rules contained in the Code of Ethics will help raise awareness and provide useful information that exceeds the requirements of the applicable provisions to all employees and all those who engage with the Company in any capacity. In fact, the aim is to ensure that all the persons involved conduct their work fairly and transparently in line with the ethical and social values which guide the Company in the pursuit of its own objects and which must in any event be capable of preventing the commission of the offences set out in the Decree.

The rules of conduct contained in the Organisational Model supplement those contained in the Company’s Code of Ethics. The Organisational Model and the Code of Ethics have been communicated to all employees and can be downloaded from the company website:

Download Organisational Model